1 DIANA S. EBRON, ESQ. Nevada Bar No. 10580 2 E-mail: [email protected] JACQUELINE A. GILBERT, ESQ. 3 Nevada Bar No. 10593 E-mail: [email protected] 4 KAREN L. HANKS, ESQ. Nevada Bar No. 9578 5 E-mail: [email protected] KIM GILBERT EBRON 6 7625 Dean Martin Drive, Suite 110 Las Vegas, Nevada 89139 7 Telephone: (702) 485-3300 Facsimile: (702) 485-3301 8 Attorneys for SFR Investments Pool 1, LLC

9 UNITED STATES DISTRICT COURT

10 DISTRICT OF NEVADA

11 BANK OF AMERICA, N.A., Case No. 2:16-cv-00579-RFB-EJY 12 Plaintiff, NOTICE OF SETTLEMENT AND 13 vs. STIPULATION AND ORDER TO EXTEND STAY OF LITIGATION 14 THE WILLOWS HOMEOWNERS ASSOCIATION; SFR INVESTMENTS POOL 15 1, LLC; and ABSOLUTE COLLECTION SERVICES, INC., 16 Defendants. 17 18 PLEASE TAKE NOTICE that Bank of America, N.A. (“BANA”) and SFR Investments 19 Pool 1, LLC (“SFR”) have reached a global settlement in principal on multiple properties, 20 including the Property at issue in this case. The settlement will resolve all claims between BANA 21 and SFR. 22 BANA and SFR have agreed to stay the litigation for ninety (90) days to allow additional 23 time to finalize settlement. This will also provide an opportunity for BANA to discuss the potential 24 for settlement as to its claims against The Willows Homeowners Association (the “Association”). 25 Accordingly, BANA, SFR and the Association (collectively the “Parties”) are submitting 26 the instant Stipulation and Order seeking to extend the already existing stay of litigation in this 27 matter. 28 Pursuant to a Minute Order in Chambers issued on October 17, 2019, this case was 1 administratively stayed pending the result of the Nevada Supreme Court’s order of en banc 2 reconsideration in the case Bank of America, N.A. v. Thomas Jessup, LLC Series VII. [ECF No. 3 63.] The Minute Order set a deadline of 30 days after the stay was lifted for refiling dispositive 4 motions. [ECF No. 63.] The Nevada Supreme Court issued its Order of en banc reconsideration 5 on May 7, 2020. Bank of America, N.A. v. Thomas Jessup, LLC Series VII,

(Nev. 6 2020) (unpublished disposition), thereby resolving that issue. While the issuance of the Order did 7 not automatically lift the stay in this case, in an abundance of caution, the Parties hereby stipulate 8 to vacate the dispositive motion deadline set by the Court’s October 7, 2019, Order, and stipulate 9 to extend the stay of litigation for ninety (90) days to allow additional time to finalize settlement. 10 … 11 12 … 13 14 … 15 16 … 17 18 … 19 20 … 21 22 … 23 24 … 25 26 … 27 28 … 1 The Parties further request the court set a deadline for filing a status report regarding the 2 || settlement for ninety (90) days from entry of this Stipulation and Order. This request to stay is 3 || being made in the interest of preserving judicial resources and, as set forth above, to allow 4 || additional time to finalize settlement. The Parties reserve the right to move to lift the stay and 5 || reinstate deadlines before the ninety (90) days if any of them choose to do so. 5 DATED this 8th day of June, 2020. DATED this 8th day of June, 2020.

KIM GILBERT EBRON AKERMAN LLP /s/ Jacqueline A. Gilbert /s/ Holly E. Walker 9 JACQUELINE A. GILBERT, ESQ. DARREN T. BRENNER, ESQ. Nevada Bar No. 10593 Nevada Bar No. 8386 10 7625 Dean Martin Drive, Suite 110 HOLLY E. WALKER, ESQ. Las Vegas, Nevada 89139 Nevada Bar No. 14295 11 || | E-mail: [email protected] 1635 Village Center Circle, Suite 200 Attorneys for SFR Investments Pool 1, LLC Las Vegas, NV 89134 12 E-mail: [email protected] E-mail: [email protected] 13 Attorneys for Bank of America, N.A.

SIE DATED this 8th day of June, 2020. 15 als 16 BOYACK ORME & ANTHONY

= /s/ Patrick A. Orme 17 EDWARD DEAN BOYACK, ESO. Nevada Bar No. 5229 18 PATRICK A. ORME, ESQ Nevada Bar No. 7853 19 7432 W. Sahara Ave., Suite 101 Las Vegas, NV 89117 20 E-mail: [email protected] E-mail: patrick @boyacklaw.com 21 Attorneys for The Willows Homeowners Association 22 23 ORDER 24 IT IS SO ORDERED. 25 AS 26 RICHARD F. WARE, II UNITED STATES DISTRICT JUDGE 27 DATED this 9th day of June, 2020. 28

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